Federal Income Taxation of Debt Instruments is the definitive reference for the many complicated issues involved with debt instruments. This comprehensive treatise contains clear interpretations of the basic rules governing original issue discount and imputed interest and detailed coverage of many specialized topics. In addition to complete coverage of the final OID regulations, the book covers virtually every aspect of the taxation of debt instruments and many related areas. Mailing with the 2007 Supplement is a special CD ROM that contains Microsoft® Excel® spreadsheets that accompany the tables and examples found in the text of Federal Income Taxation of Debt Instruments, Fifth Edition. The 2007 Supplement features the following new enhanced coverage: -Proposed regulations for funds held by qualified intermediaries in like-kind exchanges. -Student loans. -Production payments. -Final regulations dealing with Widely Held Fixed Investment Trusts. -Effect of a section 754 election on market discount. Proposed regulations under section 1221(a)(4) that would reverse the holdings in the Burbank Liquidating and Fannie Mae cases. PLR 200630002, which involved the question of whether a conversion of a debt obligor to an LLC is a significant modification. Section 752 regulations. Kerbaugh Empire case. Section 2006 was revised to reflect substantial changes to the inbound interest apportionment rules of Reg. §1.882-5. IRS enforcement initiative under the withholding tax rules.
